Privacy Policy

01 Who we are

This Privacy Policy explains how Smilor Consulting LLC ("Smilor Consulting," "we," "us," or "our") collects, uses and protects personal information through our website, smilorllc.com (the "Site"). Smilor Consulting LLC is a Texas limited liability company providing paint process engineering and capital project consulting services in the United States and Mexico. Smilor Consulting LLC is the party responsible for your personal information (the "controller," or responsable under Mexican law).

This policy covers the Site only. Personal and business information exchanged during a paid or proposed consulting engagement is governed by the confidentiality terms of the applicable nondisclosure agreement, master services agreement or statement of work.

02 Information we collect

Information you give us

When you complete our project inquiry form, request a consultation, email or call us, we collect what you choose to provide, which may include:

• Name, job title and company name
• Business email address and phone number
• Company location (city, state or country)
• Details about your project, facility, coating process, timeline or budget
• Any other information you include in your message

We ask that you not send confidential technical drawings, trade secrets or proprietary process data through the Site. If an engagement moves forward, we will set up a secure exchange under a signed NDA.

Information collected automatically

When you visit the Site, our hosting platform and analytics tools automatically collect limited technical information, such as:

• IP address and approximate location (city/region level)
• Browser type, device type and operating system
• Pages viewed, time on page, referring website and search terms used to find the Site
• Date and time of your visit

Sensitive information

We do not ask for, and do not want, sensitive personal information (such as health, financial account, government ID, racial or ethnic origin, or religious data) through the Site. Please do not submit it.

03 How we collect it

• Directly from you through the inquiry form, consultation requests, email, phone, or our downloadable contact card.
• Through our website platform. The Site is hosted by Squarespace, Inc., which processes Site data on our behalf.
• Through cookies and similar technologies, described in Section 5.
• From professional networks. If you contact us through LinkedIn, we receive the information LinkedIn makes available under its own privacy policy.

04 How we use your information

Necessary purposes (required to respond to you and provide our services)

• Responding to inquiries and scheduling consultations
• Evaluating whether and how we can help with your project
• Preparing proposals, statements of work and engagement documents you request
• Communicating with you about an active or proposed engagement
• Operating, securing and maintaining the Site
• Complying with legal, tax and accounting obligations, and protecting our legal rights

Secondary (optional) purposes

• Occasionally sending you industry articles, Insights posts or updates about our services
• Understanding how visitors use the Site so we can improve its content

You may opt out of secondary purposes at any time by emailing doug@smilorllc.com or using the unsubscribe link in any message. Opting out does not affect our response to your inquiry.

Visitors in Mexico may object to secondary purposes before or after providing their information.

We do not use your information for automated decision-making that produces legal or similarly significant effects on you.

05 Cookies and analytics

The Site uses cookies and similar technologies that are:

• Strictly necessary — set by Squarespace to deliver pages, keep the Site secure and remember your cookie preferences.
• Analytics — Squarespace Analytics records aggregated visit data (pages viewed, traffic sources, approximate location) to help us understand Site traffic.

You can block or delete cookies through your browser settings. Blocking strictly necessary cookies may affect how the Site works. Where a cookie banner is shown, you can manage optional cookies through it.

Do Not Track and Global Privacy Control

We do not sell personal information or use it for targeted advertising. Where we use optional analytics or advertising tools, we honor recognized browser opt-out signals such as Global Privacy Control where technically supported.

06 How we share information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share it only as follows:

• Service providers who process data on our behalf under contract, such as website hosting (Squarespace), email and document storage (e.g., Microsoft 365), form and scheduling tools, and our accounting and tax advisors. They may use the data only to provide services to us.
• Project partners, with your permission — for example, an equipment integrator or coatings supplier you ask us to coordinate with.
• Legal and safety — when required by law, subpoena or court order, or to protect our rights, property or safety, or that of others.
• Business transfer — if Smilor Consulting LLC is reorganized, merged or sold, information may transfer to the successor, which must honor this policy.

Under Mexican law, transfers to service providers acting on our behalf do not require your consent. Any other transfer will be made only with your consent where the law requires it.

07 International transfers

Smilor Consulting LLC is based in Texas, and our service providers store data primarily in the United States. If you contact us from Mexico or elsewhere, your information will be transferred to and processed in the United States, where data-protection laws may differ from those of your country.

By submitting information through the Site, you acknowledge this transfer. We apply the protections described in this policy wherever your information is processed.

08 How long we keep information

• Inquiries that do not become engagements: up to 3 years from our last contact, because industrial capital projects often take years to move forward, unless you ask us to delete it sooner.
• Client and engagement records: for the term of the engagement plus 7 years, to meet tax, accounting and contractual obligations.
• Analytics data: per the retention settings of the analytics provider, generally no more than 26 months.

When information is no longer needed, we delete or anonymize it.

09 How we protect information

We use reasonable administrative, technical and physical safeguards appropriate to the nature of the information, including encrypted (HTTPS) connections to the Site, access-controlled business accounts with multi-factor authentication, and limiting access to people who need it.

No method of transmission or storage is 100% secure, so we cannot guarantee absolute security. If we learn of a security breach affecting your personal information, we will notify you as required by applicable law.

10 Your privacy rights

Depending on where you live, you may have the right to:

• Know whether we process your personal information and access a copy of it
• Correct inaccurate information
• Delete your information
• Receive your information in a portable format
• Opt out of marketing communications, sale of personal data, targeted advertising or profiling (we do not engage in sale, targeted advertising or profiling)
• Withdraw consent you previously gave

We extend these rights to all Site visitors regardless of where they live, and we will not discriminate against you for exercising them.

Texas residents

Smilor Consulting LLC qualifies as a small business under the U.S. Small Business Administration's definition, which exempts it from most provisions of the Texas Data Privacy and Security Act. We nonetheless honor the requests above, and we will never sell sensitive personal data.

Mexico — ARCO rights

If you are located in Mexico, you have the rights of Access, Rectification, Cancellation and Opposition (derechos ARCO) and the right to revoke consent under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares. Exercising these rights is free of charge.

Send your request to doug@smilorllc.com with:

1. Your name and an email address or other means to receive our response
2. A copy of an identification document (or proof of a representative's authority)
3. A clear description of the information involved and the right you wish to exercise
4. Any document that helps us locate your information

We will respond within the timeframes set by that law. If you believe your rights have not been respected, you may contact the Mexican data-protection authority (the Secretaría Anticorrupción y Buen Gobierno).

How to make a request

Email doug@smilorllc.com with the subject line "Privacy Request." We will verify your identity before acting, using information you have already given us where possible.

You may use an authorized agent with your written permission. If we decline a request, we will explain why, and you may appeal by replying to our decision with the subject line "Privacy Appeal"; we will respond to appeals within 60 days.

11 Children

The Site is intended for business professionals and is not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided information to us, contact us and we will delete it.

12 Third-party links

The Site links to third-party sites such as LinkedIn. We are not responsible for their privacy practices; please review their policies.

13 Changes to this policy

We may update this policy as our Site or the law changes. We will post the updated policy on this page with a new effective date. If we make material changes, we will provide notice on the Site and, where required by law, seek your consent.

14 Contact us

Questions about this policy or our privacy practices: